ML062330018
| ML062330018 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/20/2006 |
| From: | Mozafari B NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Walt T Carolina Power & Light Co |
| Mozafari B, NRR/ADRO/DORL, 415-2020 | |
| Shared Package | |
| ML062330026 | List: |
| References | |
| TAC MC6630 | |
| Download: ML062330018 (13) | |
Text
September 20, 2006 Mr. Thomas D. Walt, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 ISSUANCE OF AMENDMENT REGARDING METHODOLOGY FOR LARGE BREAK LOSS-OF-COOLANT ACCIDENT ANALYSES (TAC NO. MC6630)
Dear Mr. Walt:
The Nuclear Regulatory Commission has issued the enclosed Amendment No. 209 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). This amendment is in response to your application dated March 3, 2005, as supplemented by letter dated July 6, 2006.
The amendment approves changes to the HBRSEP2 Operating License and Technical Specifications to change the methodology for large break loss-of-coolant accident analyses.
A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Brenda L. Mozafari, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosures:
- 1. Amendment No. 209 to DPR-23
- 2. Safety Evaluation cc w/encls: See next page
Mr. T. D. Walt H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 cc:
David T. Conley Mr. C. T. Baucom Associate General Counsel II - Legal Supervisor, Licensing/Regulatory Programs Department H. B. Robinson Steam Electric Plant, Progress Energy Service Company, LLC Unit No. 2 Post Office Box 1551 Carolina Power & Light Company Raleigh, North Carolina 27602-1551 3581 West Entrance Road Hartsville, South Carolina 29550 Ms. Margaret A. Force Assistant Attorney General Ms. Beverly Hall, Section Chief State of North Carolina N.C. Department of Environment Post Office Box 629 and Natural Resources Raleigh, North Carolina 27602 Division of Radiation Protection 3825 Barrett Dr.
U. S. Nuclear Regulatory Commission Raleigh, North Carolina 27609-7721 Resident Inspectors Office H. B. Robinson Steam Electric Plant Mr. Robert P. Gruber 2112 Old Camden Road Executive Director Hartsville, South Carolina 29550 Public Staff - NCUC 4326 Mail Service Center Mr. Dan Stoddard Raleigh, North Carolina 27699-4326 Plant General Manager H. B. Robinson Steam Electric Plant, Mr. Henry H. Porter, Assistant Director Unit No. 2 South Carolina Department of Health Carolina Power & Light Company Bureau of Land & Waste Management 3581 West Entrance Road 2600 Bull Street Hartsville, South Carolina 29550 Columbia, South Carolina 29201 Mr. William G. Noll Mr. Chris L. Burton Director of Site Operations Manager H. B. Robinson Steam Electric Plant, Performance Evaluation and Unit No. 2 Regulatory Affairs PEB 7 Carolina Power & Light Company Progress Energy 3581 West Entrance Road Post Office Box 1551 Hartsville, South Carolina 29550 Raleigh, North Carolina 27602-1551 Public Service Commission Mr. John H. ONeill, Jr.
State of South Carolina Shaw, Pittman, Potts, & Trowbridge Post Office Drawer 11649 2300 N Street NW.
Columbia, South Carolina 29211 Washington, DC 20037-1128 J. F. Lucas Manager - Support Services - Nuclear H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550
ML062330018 NRR-058 OFFICE LPL2-2/PM LPL2-2/LA DSS/SPWB OGC LPL2-2/BC (A)
NAME BMozafari CSola JNakoski DRoth JDixon-Herrity DATE 9/1/06 8/30/06 8/16/06 9/18/06 9/20/06 CAROLINA POWER & LIGHT COMPANY DOCKET NO. 50-261 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 209 Renewed License No. DPR-23
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Carolina Power & Light Company (the licensee), dated March 3, 2005, as supplemented by letter dated July 6, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 3.B of Renewed Facility Operating License No. DPR-23 is hereby amended to read as follows:
B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 209, are hereby incorporated in the license. Carolina Power
& Light Company shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Jennifer Dixon-Herrity, Acting Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: September 20, 2006
ATTACHMENT TO LICENSE AMENDMENT NO. 209 RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace page 3 of Renewed Facility Operating License No. DPR-23 with the attached page 3.
Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Remove Pages Insert Pages 5.0-30 5.0-30
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 209 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-23 CAROLINA POWER & LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261
1.0 INTRODUCTION
By letter dated March 3, 2005, as supplemented by letter dated July 6, 2006, the Carolina Power & Light Company (CP&L, licensee) requested changes to the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2) Operating License and Technical Specifications (TS),
specifically, changes to the HBRSEP2 methodology for large break (LB) loss-of-coolant accident (LOCA) analyses. The licensee requested approval to apply the Nuclear Regulatory Commission (NRC)-approved Framatome best estimate (BE) LBLOCA methodology described in EMF-2103(P)(A) Realistic Large Break Loss-of-Coolant Accident Methodology for Pressurized Water Reactors, Revision 0, April 2003, for HBRSEP2.
The July 6, 2006, letter provided clarifying information that did not change or expand the scope of the initial proposed no significant hazards consideration determination.
The NRC staff reviewed the licensees evaluations of the emergency core cooling system (ECCS) performance analyses for HBRSEP2 that were done in accordance with the EMF-2103(P)(A) methodology, operating at about 102 percent of the licensed core power of 2339 mega-watts thermal (MWt). For HBRSEP2 the LOCA analyses were conducted assuming the plant uses Framatome M5 fuel assemblies.
HBRSEP2 is a 3-loop pressurized water reactor (PWR) of Westinghouse design, enclosed within a large, dry containment. The ECCS consists of low pressure safety injection (LPSI) flow and high head safety injection (HHSI) flow delivered to the cold legs, and three accumulators with a cover gas pressure of about 600 psia, also injecting into the cold legs. The shut-off head of the HHSI pumps is about 1500 psia. The analyzed core power was the current licensed power level of 2339 MWt plus uncertainties.
2.0 REGULATORY ANALYSIS
The LBLOCA analyses were performed to demonstrate that the system design would provide sufficient ECCS flow to transfer the heat from the reactor core following a LOCA at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling would be prevented, and (2) the clad metal-water reaction would be limited to less than enough to compromise cladding ductility and would not result in excessive hydrogen generation. The
NRC staff reviewed the analyses to ensure that it reflected suitable redundancy in components and features; and suitable availability of interconnections, leak detection, isolation, and containment capabilities such that the safety functions would be accomplished assuming a single failure or for LOCAs considering the availability of onsite power (assuming offsite electric power is not available with onsite electric power available or onsite electric power is not available with offsite electric power available). The acceptance criteria for ECCS performance are provided in Section 50.46 of Title 10 of the Code of Federal Regulations (10 CFR 50.46),
and were used by the NRC staff in assessing the acceptability of the EMF-2103(P)(A) methodology for HBRSEP2.
The NRC staff also reviewed the limitations and conditions stated in its safety evaluation report supporting approval of the methodology and the range of parameters described in the EMF-2103 topical report in its assessment of the acceptability of the methodology for HBRSEP2.
3.0 LBLOCA ANALYSIS In the July 6, 2006, submittal, the licensee stated, Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. (PEC) and its vendor, AREVA NP Inc. have ongoing processes which assure that the input parameters for the HBRSEP2 LOCA analyses conservatively bound the ranges and values of the as-operated plant parameters. The NRC staff finds that this statement, along with the generic acceptance of the EMF-2103(P)(A) methodology, provides assurance that EMF-2103(P)(A) and LBLOCA analyses performed using that the methodology apply to HBRSEP2 operated at the current licensed power of 2339 MWt.
In its submittal, the licensee provided the results for the HBRSEP2 BE LBLOCA analyses at 2339 MWt (plus uncertainties) performed in accordance with the EMF-2103(P)(A) methodology.
The licensees results for the limiting peak cladding temperature (PCT), the maximum cladding oxidation (local), and the maximum core-wide cladding oxidation are provided in the following table along with the acceptance criteria of 10 CFR 50.46(b).
TABLE 1: LARGE BREAK LOCA ANALYSIS RESULTS EMF-2103 10 CFR 50.46 Limits Parameter HBRSEP2 Results Limiting Break Size/Location DEG/PD N/A Cladding Material M5* (Cylindrical) Zircaloy or Zirlo Peak Clad Temperature 1952 oF 2200 oF (10 CFR 50.46(b)(1))
Maximum Local Oxidation 1.82 percent 17.0 percent (10 CFR 50.46(b)(2))
Maximum Hydrogen Generation 0.04 percent 1.0 percent (10 CFR 50.46(b)(3))
DEG/PD is a double ended guillotine break at the pump discharge.
- An exemption from 10 CFR 50.46 for use of M5 cladding in HBRSEP2 was previously granted.
In assessing the analyses for HBRSEP2, the NRC staff considered the concern that present fuel may have pre-existing oxidation that must be considered in its LOCA analyses. The NRC staff notes that the fuel with the highest LOCA generated oxidation will likely not be the same fuel that has the highest pre-LOCA oxidation. It should be noted that the NRC staff is discussing a concern with the Framatome about the statistical approach used in the EMF-2103(P)(A) LBLOCA methodology for determining local oxidation and maximum hydrogen generation. Section 3.1.4 of this safety evaluation provides additional information on this concern. Even with the NRC staffs concern, the NRC staff considered that the calculated local oxidation is sufficiently low (1.82 percent) that the pre-accident oxidation would have to be incredibly high (greater than 15 percent) for any power-producing rod in the core to exceed the 10 CFR 50.46(b)(2) total oxidation limit of 17 percent. The NRC staff finds that this appropriately addresses the issue with pre-LOCA oxidation at HBRSEP2.
The concern with core-wide oxidation relates to the amount of hydrogen generated during a LOCA. Because hydrogen that may have been generated pre-LOCA (during normal operation) will be removed from the reactor coolant system throughout the operating cycle, the NRC staff notes that pre-existing oxidation does not contribute to the amount of hydrogen generated post-LOCA and therefore, it does not need to be addressed when determining whether the calculated total core-wide oxidation meets the 1.0 percent criterion of 10 CFR 50.46(b)(3).
As discussed previously, PEC requested Framatome to conduct the BE LBLOCA analyses for HBRSEP2 at the licensed power level of 2339 MWt (plus uncertainties) using the NRC approved EMF-2103(P)(A) methodology. The NRC staff concluded that the results of these analyses (see Table 1) demonstrated compliance with 10 CFR 50.46(b)(1) through (b)(3) for licensed power levels of up to 2339 MWt.
3.1 OTHER TECHNICAL ISSUES 3.1.1 Breaks at the Top and Side of Cold Leg Pump Discharge Piping A LOCA scenario of concern to the NRC staff is a break of a size that could result in extended core uncovery requiring operator action to depressurize and establish low pressure recirculation cooling. The NRC staffs concern applies to plants with deep reactor coolant system pump (suction) loop seals (such as HBRSEP2). The size of break for this scenario falls within the range of breaks analyzed by both small break (SB) and LBLOCA methodologies. To the extent that the SBLOCA and LBLOCA analyses overlap on break size, the more conservative results are considered limiting by the NRC staff. A split break at the top or side of cold leg pump discharge piping could lead to this scenario.
In response to an NRC staff request for additional information on cold leg slot breaks, the licensee referred to EMF-3030(P) Robinson Nuclear Plant Realistic Large Break LOCA Analysis, dated February 27, 2004, in its July 6, 2006, letter. The licensee stated that [s]lot breaks at the top and side of the cold leg piping were evaluated generically, based on relevant engineering experience for 3-loop and 4-loop recirculating steam generator plants. As noted in Table 3.4 of EMF-3030(P), the evaluation is documented in the realistic LBLOCA analysis guidelines; therefore, slot breaks at the top and side of the pipe have been considered for HBRSEP, Unit No. 2. The licensee also indicated that HBRSEP2 was explicitly considered in the generic evaluation and that the high loop seal elevations at HBRSEP, Unit No. 2, resulted in a minor amount of core uncovering, with a minimum collapsed liquid level of 9.45 feet and
minor cladding heatup to approximately 600 oF. Further, the licensee indicated that the HBRSEP2 emergency operating procedures direct operator actions, such as aligning ECCS for hot leg recirculation, that will mitigate the consequences of the core uncovering by suppressing core boiling and/or minimizing the amount of time that the core is partially uncovered.
Based on the relatively low PCTs associated with slot breaks based on the EMF-2103(P)(A) methodology, and the existing emergency operating procedure guidance, the NRC staff concludes that the issue related to compliance with 10 CFR 50.46(b)(1)-(4) has been adequately addressed for HBRSEP2.
3.1.2 Post-LOCA Boron Precipitation This issue was considered in the original licensing of HBRSEP2. The LBLOCA methodology described in EMF-2103(P)(A) does not affect this issue. Therefore, the NRC staff considers that the status of this issue is unchanged by the application of the EMF-2103(P)(A) LBLOCA methodology to HBRSEP2.
3.1.3 Downcomer Boiling The NRC staff has raised concerns to the licensee with the modeling of downcomer boiling in LBLOCA analysis methodologies. These concerns are being discussed with the methodology vendors to develop solutions. The NRC staffs concerns are primarily associated with PWRs with subatmospheric or ice condenser containments, and to a lesser extent 3-loop Westinghouse PWRs. Consistent with the requirements of 10 CFR 50.46, HBRSEP2 is required to evaluate the effect of the generic resolution applicable to its class of plant and to revise its LBLOCA analyses as appropriate.
During the reflood stage of post-LOCA ECCS operation, latent heat from the reactor vessel, the core barrel, and other vessel internals is transferred to the water in the downcomer of the vessel. The head of water in the downcomer provides the driving force for reflooding the core.
The heat transferred to the downcomer water would reduce the density of the water and boil away water. Both of these effects reduce the driving head for reflooding of the core.
Depending on the magnitude and timing of this heat addition to the downcomer water, the core reflood rate could be adversely affected, with adverse consequences to the fuel in the core. If the LOCA analysis methodology does not correctly model heat conduction in the reactor vessel wall, the magnitude and timing of vessel wall heat deposition to the fluid in the downcomer could be non-conservatively timed, such that the PCT, oxidation, and hydrogen generation may be underestimated due to the downcomer boiling effect.
While this issue may ultimately result in higher limiting PCT, local oxidation, and maximum hydrogen generation at HBRSEP2, as shown in Table 1 of this safety evaluation, the licensee has demonstrated for the current licensed power level that there is substantial margin to the acceptance criteria of 10 CFR 50.46(b)(1), (2), and (3), respectively.
Based on the application of the NRC staff approved ECCS performance evaluation methodology described in EMF-2103(P)(A) and the substantial margin to the acceptance criteria of 10 CFR 50.46(b)(1), (2), and (3), the NRC staff determined that even with the concerns related to downcomer boiling, the HBRSEP2 LBLOCA analyses was acceptable for the current licensed power level.
3.1.4 Oxidation and Hydrogen Generation The staff is discussing with Framatome a generic concern with the BELOCA methodology described in EMF-2103(P)(A) used to determine the limiting LBLOCA oxidation and hydrogen generation. The concern is that the method used to determine the limiting LBLOCA oxidation and hydrogen generation is not consistent with Regulatory Guide 1.157, Best Estimate Calculations of Emergency Core Cooling Performance, Section 4.4, that states, The revised paragraph 10 CFR 50.46(a)(1)(i) requires that it be shown with high probability that none of the criteria of paragraph 10 CFR 50.46(b) will be exceeded, and is not limited to the peak cladding temperature criterion. However, since the other criteria are strongly dependent on peak cladding temperature, explicit consideration of the probability of exceeding the other criteria may not be required if it can be demonstrated that meeting the temperature criterion at the 95 percent probability level ensures with equal or greater probability that the other criteria will not be exceeded. The fundamental issue the NRC staff raised in various calls with Framatome is whether the statistical approach used in the methodology provides the high level of probability that the oxidation and maximum hydrogen generation criteria of 10 CFR 50.46 (b)(2) and (b)(3),
respectively, would not be exceeded.
In assessing whether the local oxidation and maximum hydrogen generation results of the HBRSEP2 BELOCA analysis provide the high level of probability that these criteria will not be exceeded, the NRC staff considered the margin between the results and the acceptance criteria, and the results of the previous 10 CFR 50, Appendix K, LBLOCA analyses. As noted in Table 1 of this safety evaluation, the BELBLOCA analyses are significantly below the limits of 10 CFR 50.46 (b)(2) and (b)(3). Even with the staffs concern with the statistical approach used in the Framatome EMF-2103(P)(A) BELBLOCA methodology, given the margin, the NRC staff concluded that there is a high probability that at the current licensed power level for HBRSEP2, the oxidation and hydrogen generation acceptance criteria of 10 CFR 50.46(b)(2) and (b)(3) would not be exceeded. Further, the previous LBLOCA analysis results described in the Robinson Final Safety Analysis Report (FSAR) for oxidation (3.5 percent) and hydrogen generation (less than 1.0 percent) bound the results using the EMF-2103 (P)(A) methodology, for HBRSEP2, operating at its current licensed power level. Because the results in the HBRSEP2 FSAR bound the EMF-2103(P)(A), results and the significant margin to the acceptance criteria of 10 CFR 50.46(b)(2) and (b)(3), the NRC staff finds the submitted LBLOCA oxidation and hydrogen generation results acceptable for HBRSEP2 operating at its current licensed power level.
3.1.5 Long Term Cooling One of the limitations specified in the NRC safety evaluation report approving EMF-2103 (P)(A) stated, "the model does not determine whether Criterion 5 of 10 CFR 50.46, long term cooling, has been satisfied. This will be determined by each applicant or licensee as part of its application of this methodology." The licensee stated [f]or HBRSEP, Unit No. 2, this was evaluated previously in report EMF-2286, "H. B. Robinson Unit 2 Extended Transfer to Cold Leg Recirculation Following a LBLOCA," and was approved by the NRC in a letter dated July 12, 2001.
For HBRSEP2, the NRC staff concluded that the existing licensing basis described in EMF-2286 was not affected by the adoption of EMF-2103(P)(A) and remains adequate as the licensing basis to demonstrate compliance with 10 CFR 50.46(b)(5) at its present power.
Therefore, as it relates to long term cooling, the NRC staff concludes that EMF-2103(P)(A) is acceptable.
3.2 LBLOCA CONCLUSIONS The NRC staffs review of the acceptability of the EMF-2103(P)(A) methodology for HBRSEP2 focused on assuring that the HBRSEP2 specific input parameters or bounding values and ranges (where appropriate) were used to conduct the analyses, that the analyses were conducted within the conditions and limitations of the NRC approved Framatome EMF-2103(P)(A) methodology, and that the results satisfied the requirement of 10 CFR 50.46(b) based on a licensed power level of up to 2339 MWt.
This Safety Evaluation documents the NRC staff review and the bases of acceptance of the EMF-2103(P)(A) BELBLOCA analysis methodology for application to HBRSEP2, and of the LBLOCA analyses discussed above, which were performed with the EMF-2103(P)(A) methodology for reference at HBRSEP2.
Based on its review as discussed above, the NRC staff concluded that the Framatome BELBLOCA methodology, as described in EMF-2103(P)(A), is acceptable for use at HBRSEP2.
Further, the NRC staff concluded that the results demonstrate high probability that the acceptance criteria of 10 CFR 50.46(b)(1), (b)(2), and (b)(3) would not be exceeded during a LBLOCA.
4.0 TECHNICAL SPECIFICATIONS 4.1 TS 5.6.5 Core Operating Limits Report (COLR)
Add the following reference to TS 5.6.5.b:
- 24. EMF-2103(P)(A), "Realistic Large Break LOCA Methodology for Pressurized Water Reactors," approved version as specified in the COLR.
EMF-2103(P)(A) is an acceptable methodology to apply to HBRSEP2 for evaluation of ECCS performance in response to LBLOCAs as discussed in Section 3 of this safety evaluation, and therefore is an appropriate reference for the LBLOCA analyses for core power up to current licensed power level of 2339 MWt.
5.0 TECHNICAL CONCLUSION The licensee has performed LBLOCA analyses for HBRSEP2 using an NRC approved Framatome methodology. The NRC staff concluded that the NRC approved Framatome methodology applies to HBRSEP2 for core power up to the current license power of 2339 MWt. The licensee's LBLOCA analyses demonstrated that the calculated LBLOCA values for PCT, local oxidation, and core-wide hydrogen generation were less than the acceptance criteria of 2200 EF, 17 percent, and 1.0 percent specified in 10 CFR 50.46(b)(1), (2), and (3),
respectively. The adoption of EMF-2103(P)(A) does not affect the current licensing basis for long term cooling.
Therefore, the NRC staff finds the licensee's LBLOCA analyses for HBRSEP2 acceptable for the current licensed power level of 2339 MWt.
6.0 STATE CONSULTATION
In accordance with the Commission's regulations, the State of South Carolina official was notified of the proposed issuance of the amendment. The State official had no comments.
7.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (70 FR 29787). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
8.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Frank Orr, NRR Date: September 20, 2006